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Held: The administrative record and notices of
determination underlying these cases are sufficient to
support meaningful judicial review.
Held, further, the Appeals officer was not
disqualified from conducting the collection hearing for
2001 and 2002 on account of prior involvement within
the meaning of sec. 6330(b)(3), I.R.C., nor does the
record otherwise call into question his impartiality.
Held, further, because the record does not show any
abuse of discretion, R’s determinations to proceed with
collection action, except to the extent modified by
settlements between the parties, are sustained.
Theodore H. Merriam and Kevin A. Planegger, for petitioners.
Frederick J. Lockhart, Jr., for respondent.
OPINION
WHERRY, Judge: These consolidated cases arise from
petitions for judicial review filed in response to Notices of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330.1 The issue for decision is whether respondent may
proceed with collection of income tax liabilities for years 2000,
2001, and 2002.
1 Unless otherwise indicated, section references are to
the Internal Revenue Code of 1986, as amended, and Rule
references are to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011